BSA/AML Examiner School Case Study

Internal Use Only

Note: If the customer's identification does not include a local or current address, obtain and document a secondary Identification form with a local or current address. Refer to the CIP Matrix for a listing of Secondary ID Verifying Account Opening Documentation (Documentary and non-Documentary verification.) • The identifying information must be verified before the account is opened. Inspect the documentation and compare the photograph and the description on the ID with the person presenting the document. • In general, two forms of identification are required to open an account. This includes a primary and a secondary piece of identification or a non-documentary verification. The Bank's required standard identification, documents and non-documentary verification are listed in the CIP Matrix. • In addition, signatures should be compared from the identification to the signature provided by the customer on the Bank's loan application or signature cards. [If there is any doubt on the identity of the customer, you may send thank-you letters or call customers after account opening to ensure that you have correct data in your files. For example, for an individual you may wish to verify the telephone number using a reverse directory to ensure the information you received is accurate.] • If the bank is not able to verify the true identity of the customer through documents, the account must be closed. This action should take no longer than 10 business days from the start of the application or opening of the account. • Awaiting TIN or SSN — For deposit accounts, have the customer certify his/her social security number (SSN) or taxpayer identification number (TIN) on IRS Form W9 or the signature card. If the customer does so, this procedure is complete. If the customer has applied for, but not received, TIN or SSN, the account but be postponed until the customer can provide all required documentation. • Missing Documents — If the customer does not have all of the required identification and information, the account cannot be opened until the customer can supply the required information. • On accounts that we open where we are not familiar with the documents —When the employee is unfamiliar with the documents produced, the customer must be directed to apply for a valid identification card issued by the state or other valid government issued document. Loan Customers and CIF • The lender should obtain identification documentation before loan closing. The lender must obtain the required identification documents from all borrowers. The customer identification program (GIP) rules apply only to those individuals who actually close on a loan; they do not apply to people who apply but are subsequently denied or withdraw their application. • In the case of a purchase money mortgage loan, the current address is considered the address of the person at the time of the loan application, not the address of the property being purchased. • As a general rule, the Bank will not keep copies of identifying documents in loan credit files. The Bank will, include the ID type, number, issuing date and state, expiration dates and a copy of the Identifying documents on our CIF files (image under CIF). The Bank is obtaining the copy of the Identification (i.e., DL, passport, etc.) as evidence that the Bank properly identified the new customer, starting a banking relationship with the AJ & R Bank. This information must be kept for five years after the loan is granted. • Lenders must also verify the information provided by the customer on the loan application against information from Bank references, employment references and credit bureau information. If you cannot verify information provided by the customer, you cannot close the loan. The account

For Training Purposes Only

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